What Does the Meaningful Use Stage 2 Timeline Extension Mean For Providers?

Dec 7, 2011

On November 30, 2011, the U.S. Department of Health and Human Services (HHS) announced that eligible providers that start participating in the Meaningful Use Stage 1 incentive programs in 2011 can delay meeting the new standards for Meaningful Use Stage 2 to 2014, rather than the original deadline of 2013. This shift in requirements was marketed as a method “to encourage faster adoption” by HHS Secretary Kathleen Sebelius.

Sebelius said, “When doctors and hospitals use health IT, patients get better care and we save money. We’re making great progress, but we can’t wait to do more.”

Logically, it seems counterintuitive that a delay in a deadline would encourage faster adoption rates by providers. But, here is how the incentive is supposed to work:

Prior to the delay, if a provider completed Stage 1 Meaningful Use in 2011, then they would have to complete Stage 2 Meaningful Use by 2013.

If a provider completed Stage 1 Meaningful Use in 2012, then they would have to complete Stage 2 Meaningful Use by 2014.

Thus, in order to lock in the 2014 deadline, it is suspected that many providers who were capable of attesting to Meaningful Use Stage 1 in 2011 were instead purposely waiting until 2012 to attest.

HHS officials said they are confident the timeline extension will encourage providers to accelerate their adoption of EHRs. There is now a major advantage to attesting to Stage 1 in 2011: Providers who first attest in 2011 can get three payment years for meeting Stage 1 requirements. Providers first attesting in 2012 will only get two payment years under Stage 1.

This announcement has no impact on eligible hospitals that had not already attested in 2011, only eligible providers who have not yet attested. Eligible hospitals are on a fiscal calendar that ends in September and thus will not have the opportunity to attest in 2011. Eligible providers have up to 60 days after the end of the calendar year to submit required data.

HHS indicated that the announcement is based on input from the healthcare community that the current schedule for Stage 2 compliance in 2013 was unrealistic. This sentiment was largely due to the fact that the Stage 2 rules would not be released until June 2012. Once the rules were released, the EHR vendors would first need to design, release and certify compliant software. After which the provider would have been responsible for upgrading and collecting the required data before the end of year 2013.

HHS claims to be working towards a realistic balance between achieving desired results of EHR implementation with the practical realities that providers are facing in implementing EHR systems. However, there are trade-offs to consider in this approach:

On the positive side, more providers will likely implement EHRs sooner than they would have otherwise. Although only slightly sooner, since this announcement was made towards the end of the year.

On the negative side, there are likely many providers and hospitals that would have stepped up to the challenge of a 2013 deadline for Stage 2. But with the delay, most will likely take their time and implement Stage 2 in 2014.

Since Stage 2 gets the industry much closer to greater interoperability and quality of care, it is disappointing to see that hospitals and providers will not be challenged to at least try to reach the Stage 2 metrics sooner. But on the brighter side, maybe this will allow the industry to achieve the Stage 2 metrics together in a more consistent and controlled manner.